UNITED BREWERIES LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX , CIRCLE-7(1)(1), BENGALURU

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

Pricing Officer-TOP under Section 92CA could be invalid and bad in law. 7. It is for this precise reason, Tribunal has rightly held that order passed by the TPO and. DRP is unsustainable in the eyes of law. The said finding is based on the authoritative principles enunciated by the Hon'ble Supreme Court in Kolhapur Canesugar Works

WIPRO GE HEALTHCARE PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.291/Bang/2022 Assessment Year: 2017-18

Price received 8,70,35,80,565/- Shortfall 84,58,60,310/- 9.3 The ld. A.R. submitted that the adjustment made by the TPO of Rs. 84,58,60,310/- in the Software Development Segment has IT(TP)A No.291/Bang/2022 Wipro GE Healthcare Pvt. Ltd., Bangalore Page 42 of 64 been adopted by the AO in the Draft assessment order

WIPRO GE HEALTHCARE PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

section 40(a)(ia) of the Act by concluding that the lease rentals, if treated to be as revenue expenses would be liable to Tax Deduction at Source ("TDS") under section 1941 of the Act, without Page 50 of 65 IT(TP)A No.285/Bang/2021 M/s. Wipro GE Healthcare Pvt. Ltd., Bangalore appreciating the fact that the expense does not warrant

M/S SCANIA COMMERCIAL VEHICLES INDIA PVT LTFD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(1)(1), BANGALORE

The Appeal of the Assessee is allowed

Bench: Shri Prashant Maharishi, Vice – & Shri Keshav Dubey

transfer pricing adjustments have been resolved under the mutual agreement procedure and therefore all the grounds relied there to are not to be decided as withdrawn. 3. Therefore, the only issue was with respect to the balance ground of appeal relating to corporate tax additions which are ground no. 17, 18 and 19 of the appeal. Thus, these

JOINT COMMISIONER OF INCOME TAX (LTU) , BANGALORE vs. M/S TEXAS INSTRUMENTS INDIA PVT LTD , BANGALORE

In the result, the appeal by the revenue is dismissed and the appeal by the assessee is partly allowed

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

194I nor 194C of the Act are attracted to lease financing of motor vehicles and therefore there could be no disallowance under section 40(a)(ia) of the Act. In so far as the applicability of provisions of section 40(a)(ia) of the Act in respect of lease rentals paid for lease of equipment is concerned, it is seen

TEXAS INSTRUMENTS (INDIA) PRIVATE LIMITED ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTU , BANGALORE

In the result, the appeal by the revenue is dismissed and the appeal by the assessee is partly allowed

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

194I nor 194C of the Act are attracted to lease financing of motor vehicles and therefore there could be no disallowance under section 40(a)(ia) of the Act. In so far as the applicability of provisions of section 40(a)(ia) of the Act in respect of lease rentals paid for lease of equipment is concerned, it is seen

MARVELL INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(1), BENGALURU

In the result, the appeal filed by the assessee is partly allowed

Bench: Shri Waseem Ahmed & Shri Rahul Chaudharym/S. Marvell India Private Limited 10Th Floor, Tower D & E Global Technology Park, Marathahalli Outer Ring Road Devarabeesanahalli Village Varthurhobli Bangalore 560 103 ………. Appellant [Pan: Aaecm5559R]

transfer Agreement (BTA) had acquired business from the entities viz. Global Foundries Engineering Private Limited and Aquantia Semiconductors India Private Limited. Details of the same are tabulated as under: 4 Assessment Year 2020-2021 SNo Name of the Entity Date of BTA Amount of xx Goodwill 1 Global Foundries 05 Nov 2019 17,69,42,384 xx Engineering Private

ADDL/JOINT COMMISSIONER OF INCOME TAX (LTU) , BANGALORE vs. M/S TEXAS INSTRUMENTS (INDIA) PVT LTD , BANGALORE

In the result, the appeal filed by the assessee is partly allowed and appeal of the revenue is dismissed

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

transfer pricing adjustment of Rs.140.84 crores. The assessee challenged the addition by filing IT(TP)A No.525 /Bang/2019 M/s. Texas Instruments (India) Pvt. Ltd., Bangalore Page 9 of 18 the appeal before Ld. CIT(A) and got partial relief. Aggrieved, both the parties have filed appeals before us on the issues discussed above. 6. We shall first take

M/S TEXAS INSTRUMENTS (INDIA) PVT LTD ,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX LTU , BANGALORE

In the result, the appeal filed by the assessee is partly allowed and appeal of the revenue is dismissed

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

transfer pricing adjustment of Rs.140.84 crores. The assessee challenged the addition by filing IT(TP)A No.525 /Bang/2019 M/s. Texas Instruments (India) Pvt. Ltd., Bangalore Page 9 of 18 the appeal before Ld. CIT(A) and got partial relief. Aggrieved, both the parties have filed appeals before us on the issues discussed above. 6. We shall first take